Policymakers find themselves increasingly occupied with ATS claims arising from conduct that occurred in other countries and which has no significant connection to the United States — claims that may not be consistent with our own government’s policies for promoting human rights. Although this issue of “extraterritorial” application has been inherent in every ATS case that has involved injuries caused by foreign corporations outside the United States, it has evaded review in every instance, and — until the Supreme Court heard arguments recently in Kiobel v. Royal Dutch Petroleum — it appeared that the proliferation of ATS cases in that particular context might continue.